The new Home Mortgage Disclosure Act reporting requirements have been in place since the beginning of the year, but lenders are still adjusting to how they work in practice.
"There's a decommissioning psychologically of the old process which creates many, many hiccups during the first 90 to 100 days after the effective date of the rule," said Pam Perdue, chief regulatory officer and executive vice president of compliance systems provider Continuity.
Automation is handling a lot of the compliance burden, but lenders also need to make sure their policies, practices and training are aligned with the practical realities of implementation.
"Most of the heavy lifting with the technology development is done, but there is still a tremendous amount of work that the lenders themselves have to account for," said Paul Christison, compliance product manager at vendor WGS.
From mixed messages about enforcement to complexities involved in determining which types of loans are now reportable, mortgage lenders think hard about how they are handling with the new rules because ultimately they, not their vendors, are the ones responsible for complying with them.
"I hear people say, 'We're waiting on the vendor' or 'the vendor couldn't do this because the vendor didn't let us test it out.' Throw that out. That's not productive thinking at all. We're accountable," said Ben Giumara, director of legal and regulatory affairs at Embrace Home Loans.
Here's a look at five potential missteps mortgage lenders transitioning to new Home Mortgage Disclosure Act rules need to steer clear of.